Version: 1.2

Date: January 2021 

Prepared by: USDA APHIS VS 

Veterinary Services Integrated 

Surveillance Modules (VSISM) 

Technology, Planning, Architecture, & E-Government

Privacy Impact Assessment 
Privacy Impact Assessment 

USDA APHIS VSISM

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Privacy Impact Assessment for the

Veterinary Services Integrated Surveillance 

Modules (VSISM)

January 2021

Contact Point 

Orlando Baca

USDA APHIS Veterinary Services

Reviewing Official 

Tonya Woods

Director, Freedom of Information and Privacy Act Staff

United States Department of Agriculture

(301) 851-4076 
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Abstract 

• This Privacy Impact Assessment (PIA) is for the USDA, Animal and Plant Health 

Inspection Service (APHIS), Veterinary Services (VS), Veterinary Services Integrated 

Surveillance Modules (VSISM). 

• USDA APHIS VSISM is an enterprise-level (business-wide) animal health and 

surveillance electronic information management system. It provides an electronic means 

of data input, data transmission, data storage, and data reporting. This system enables 

USDA APHIS to take a comprehensive and integrated approach to collecting and 

managing animal health data for disease management and surveillance programs.

• This PIA was conducted as part of annual assessment documents update. 

Overview 

The USDA APHIS VSISM is an animal health and surveillance system which provides enterpriselevel surveillance and animal health program data for numerous species and diseases to facilitate 

the detection, management, prevention, investigation, control and eradication of animal diseases. 

The USDA APHIS VSISM maintains the following data on collection site, animal, and specimen 

information, as well as conditions to test for on the specimens, depending on the stream and 

condition of interest.

Syndromic Observations

These are qualitative observations about a given animal grouped by important clinical 

subdivisions of the animal such as the nervous system, cardiovascular or musculoskeletal. 

This data is not characteristic of a disease, but of an animal. It can be used to assess the 

probability of a given disease and thus inform testing requests and epidemiological surveys. 

Currently some submissions capture clinical signs, but it is in reference to a specific disease, 

and there is no cross program standard. 

Lab Submission Test Orders and Results

These include the recording of laboratory test results and interpretations for specimens 

submitted to a diagnostic lab. These results and interpretations are specific to a condition, 

unlike the recording of syndromic observations which may be related to more than one 

condition. Test results represent a quantitative determination of a given disease incidence in 

an animal determined through testing of specimens taken from the animal. The results are 

used to support specimen or animal level interpretations which have direct surveillance 

consequences. 

Compliance Observations

This category is comprised of observations of the operating parameters of a facility engaged 

in specific production practices characterized by discrete quantitative or semi-quantitative 

parameters. For example, a waste feeder facility may require the temperature of the cooker to 
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be within a certain range, or a herd or flock certification1 program may have requirements in 

place regarding fencing, allowed feed, etc. In general this data will be characteristic of either 

the premises or the animal group as a whole, not of individual animals. 

The USDA APHIS VSISM supports the Veterinary Services mission to protect and improve the 

health, quality, and marketability of our nation's animals by providing a nationwide repository of 

animal health and productivity information. 

USDA APHIS VSISM also maintains name, address, and phone information for individuals 

identified as contacts for premises (locations) and owners of animals or animal related operations 

involved with the various programs. Because of the variable nature of the premises, including sole 

proprietorships, and the undocumented relationship of the contact to the premises, many of the 

contacts are private citizens. 

The USDA APHIS VSISM is funded by Congress through appropriated funds for the Animal 

Health Technical Services budget line item. The system received a renewal of its Authority to 

Operate (ATO) in May 2021. VSISM has a security categorization of “Moderate”.

Section 1.0 Characterization of the Information 

The following questions are intended to define the scope of the information requested and/or 

collected as well as reasons for its collection as part of the program, system, rule, or technology 

being developed. 

1.1 What information is collected, used, disseminated, or maintained in 

the system? 

Information/Record Type Component Data (Examples)

Premises Physical location of a business or animal 

herd/flock 

Observations Attributes of the location, subjects, and samples 

collected

Test Orders and Results Test submission information and test results for 

diseases such as Classical Swine Fever, Swine 

Brucellosis, Pseudorabies, or Foot and Mouth 

Disease, 

Subject Species, breed, sex, age, classification, and any 

associated individual animal or animal group 

identifiers.

Other Specific ad-hoc data, miscellaneous 

identification numbers such as the regulatory 
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official ID, animal observations at the 

collection site, compliance observations, and 

licensing information for persons and locations.

Lab Testing laboratory

Data Collection Stream Method or means by which the data is being 

collected, such as On-Farm, Slaughter, 

Slaughter Market, or Diagnostic Lab

Commodity Group Overall surveillance program such as Swine 

Health

Person Information Name, contact information for collector, 

submitter, owner, designated epidemiologist

1.2 What are the sources of the information in the system? 

The source of information for USDA APHIS VSISM is: 

• information collected from visits to production facilities, slaughter plants, or other 

locations

1.3 Why is the information being collected, used, disseminated, or 

maintained? 

The purpose of the USDA APHIS VSISM system is to allow animal health officials to 

effectively manage animal disease, pest and surveillance programs by providing:

a) rapid detection and effective response to animal disease and animal pest events in the 

United States thereby reducing the spread of infections to new flocks/herds;

b) epidemiological analysis, including diagnostic testing, surveillance activities, and 

other factors of epidemiologic importance for evaluating disease risk;

Summarized animal disease information is reported to the (OIE) Office International des 

Epizooties (World Organization for Animal Health). Some animal disease information is 

shared with world trading partners provided for risk analysis to demonstrate that US 

agricultural animal products are safe for export to other countries. Most risk analysis 

information is aggregated information and does not describe detailed record information. 

Some animal disease information is shared with state and federal wildlife agencies, as 

animal disease frequently crosses over between domesticated animals and wildlife. 

Some animal disease information is shared with state and federal public health agencies, 

as animal disease can cross over between domesticated animals and humans. 

All information for a State, by definition, is shared with state animal health officials and 

state animal health databases for that State. State employees who are authenticated users 

have access to all the data collected about animals in their state. Federal users have access 
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to data to meet the mission of Veterinary Services. State partners use the information to 

manage animal diseases in their state.

1.4 How is the information collected? 

The information collected from states, users, individuals and/or businesses in the general 

public is collected on OMB approved form VS 10-4, 6-35, 10-12 and 5-38 at a minimum, 

as well as approved non-forms. The information is entered directly into the USDA APHIS 

VSISM application by a state or federal employee entering information provided in 

person, over the phone, in an email, or letter by a producer. Members of the public do not 

access system to enter data themselves. Data is input by authenticated state and federal 

employees.

1.5 How will the information be checked for accuracy? 

Data collected from customers, USDA sources and non-USDA sources are verified for 

accuracy, relevance, timeliness and completeness by USDA and state employees at the 

time the data is collected. These employees are responsible for the review and accuracy of 

the data. Verification of data records occurs on an as-needed basis. Person address 

information only provides value during the lifecycle of the laboratory testing process and 

is not validated beyond the time of collection. Also, there are limited systematic data 

entry constraints to ensure entry completeness and acceptable values. 

1.6 What specific legal authorities, arrangements, and/or agreements 

defined the collection of information? 

• The Animal Damage Control Act of 1931, 7 U.S.C. 8301 et seq. of the Animal Health 

Protection Act 

• The Animal Health Protection Act, 7 U. S. C. 8301-8317 

• 7 USC Sec. 7629 

• The Farm Security and Rural Investment Act of 2002 

• Public Health Security and Bioterrorism Preparedness and Response Act of 2002 116 

Stat 674-678 

• The Homeland Security Presidential Directive 9.

• Farm Bills - an omnibus, multiyear law that governs an array of agricultural and 

food programs

1.7 Privacy Impact Analysis: Given the amount and type of data 

collected, discuss the privacy risks identified and how they were 

mitigated. 

Unauthorized disclosure of employee and other personal data, as identified in Section 1.1 

above, was the primary privacy risk identified in the PTA. USDA APHIS, including the 
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VS Executive Team, District and Commodity Directors, Assistant District Directors, 

Centers for Epidemiology and Animal Health (CEAH), and State Veterinarians are all 

responsible for protecting the privacy rights of the employees and other persons identified 

in the VSISM as required by applicable State and Federal laws. Specific mitigation 

activities are:

• All access to the data in the system is controlled by formal authorization. Each 

individual’s supervisor must identify (authorize) what functional roles that individual 

needs in the USDA APHIS VSISM system. 

• Access to USDA APHIS VSISM is controlled by the USDA eAuthentication system 

and/or APHIS VPN. 

• The application limits access to relevant information and prevents access to 

unauthorized information. 

• All users receive formal system training and are required to sign Rules of Behavior on 

an annual basis as part of the USDA mandatory information system security 

awareness training.

• At the login screen of the application the warning banner must be acknowledged 

before users are allowed access. 

Section 2.0 Uses of the Information 

The following questions are intended to delineate clearly the use of information and the 

accuracy of the data being used. 

2.1 Describe all the uses of information. 

The data is used for routine animal health surveillance, management of domestic animal 

disease and pest control programs, and to monitor for and respond to the introduction of 

foreign animal diseases. 

State Veterinarians and State Animal Health officials, as co-owners of the data, have the 

discretion to share information stored in the USDA APHIS VSISM relevant to premises or 

persons within their state in accordance with state laws and regulations via public web 

sites and/or may store such information in animal health and surveillance management 

databases developed by State IT developers, contractors or other third party software 

vendors in a manner that provides secure data access. 

Certain disease information reported by State and/or Federal employees is recorded in 

USDA APHIS VSISM. These reports are then summarized by APHIS in reports to the 

(OIE) Office International des Epizooties (World Organization for Animal Health). No 

‘customer’, ‘employee’ or ‘other’ private information is published or distributed to OIE. 

The Center for Epidemiology for Animal Health (CEAH) and the Commodity Health

Centers have agency responsibility for reporting surveillance and program management 
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activities on a nationwide basis. The CEAH and the Commodity Health Centers have 

direct access to the USDA APHIS VSISM data and provide and publish summaries to the 

public and our trading partners.

2.2 What types of tools are used to analyze data and what type of data 

may be produced? 

USDA APHIS VSISM data is aggregated into a Data Analytics Warehouse where it is 

processed and visualized using business analysis tools such as Alteryx and Tableau. Data 

is also analyzed in Excel spreadsheets and by using SAS® (a statistical application). 

VSISM also uses VS Data Integration Services (a component of the APHIS Marketing 

Regulatory Services Amazon Web Service General Support System (MRP AWS GSS)) to 

integrate data with other VS data sources for performing mission critical analysis of 

surveillance data. Aggregated data is used to produce summary reports for stakeholders.

2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

USDA APHIS VSISM does not use commercial or publicly available data.

2.4 Privacy Impact Analysis: Describe any types of controls that may be 

in place to ensure that information is handled in accordance with the 

above described uses. 

• Privacy rights of the employees and other persons will be protected by USDA APHIS VS 

management within the limits of the Privacy Act of 1974. USDA APHIS VSISM has 

security controls to address access/security of information. 

• All access to the data in the system is controlled by formal authorization. Each 

individual’s supervisor must identify (authorize) what functional roles that individual 

needs in the USDA APHIS VSISM application. 

• All requests for access to the system are verified by user identification and 

authentication. Users must have a government issued login and password that is controlled 

and managed either at the Veterinary Services, National, District or local offices or in the 

case of local State databases the State Veterinarian’s office. 

• The USDA APHIS VSISM application limits access to relevant information and prevents 

access to unauthorized information through role-based access. 

• All users receive security basics training and are required to sign rules of behavior before 

being given access to the system. Additionally, all users receive security basics refresher 

training and sign rules of behavior on an annual basis.

• At the application login screen the warning banner must be acknowledged before users are 

allowed to log into the application.

Section 3.0 Retention 
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The following questions are intended to outline how long information will be retained after the 

initial collection. 

3.1 How long is information retained? 

The records within the USDA APHIS VSISM application are considered permanent until 

the actual records retention scheduled is approved by NARA. 

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

APHIS is currently developing a records schedule to cover these records.

3.3 Privacy Impact Analysis: Please discuss the risks associated with the 

length of time data is retained and how those risks are mitigated. 

Unauthorized disclosure of contact information, as identified in Section 1.1 above, is the 

primary privacy risk, as identified by the PTA. Personally Identifiable Information (PII) is 

limited to names, addresses, email and phone numbers of submitters/collectors and 

premises/animal owners, and premises identification numbers. The benefit of having that 

data available for premises backtracking and other trending information during an 

emergency overrides any risk of unauthorized disclosure. All records will be retained 

while VS awaits NARA disposition and retention scheduling. USDA APHIS VSISM

maintains information in a secure manner and will dispose of information per APHIS 

Directive 3440.2 and approval NARA disposition authority.

Section 4.0 Internal Sharing and Disclosure 

The following questions are intended to define the scope of sharing within the United States 

Department of Agriculture.

4.1 With which internal organization(s) is the information shared, what 

information is shared and for what purpose? 

All data is available (for the areas/states for which they have responsibility) to USDA 

APHIS, including District and Commodity Directors, Assistant District Directors, district 

and national staff, Centers for Epidemiology and Animal Health (CEAH), for program 

implementation, oversight, and reporting. Data is also shared with the USDA Office of the 

Chief Information Officer’s Data Lake environment for Tableau visualization.

4.2 How is the information transmitted or disclosed? 

The APHIS and state users have access to the USDA APHIS VSISM through the APHIS 

Enterprise Infrastructure (AEI). For reporting, user roles and row-level permissions 

provide controlled access via Tableau tools and VS Data Integration Services (a 
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component of the APHIS Marketing Regulatory Services Amazon Web Service General 

Support System (MRP AWS GSS)). Data is transmitted to the OCIO Enterprise Tableau 

securely over the network.

4.3 Privacy Impact Analysis: Considering the extent of internal 

information sharing, discuss the privacy risks associated with the 

sharing and how they were mitigated. 

Unauthorized disclosure of contact information, as identified in Section 1.1 above, is the 

primary privacy risk to information shared internally to APHIS. These risks are mitigated 

through USDA APHIS VSISM and MRP Azure Cloud GSS security controls as 

delineated in the current USDA APHIS VSISM System Security Plan. Further, the animal 

health professionals who have access to the data are trained in the proper use and 

dissemination of this data. All access must be approved before it is granted. VS, where 

feasible and within the technical limitations, ensures activities within the VSISM are 

audited, PII is used only for authorized purposes and in a manner that is compatible with 

Privacy Act, and PII use is minimized to the extent necessary to meet the mission needs of 

the VS surveillance program.

Section 5.0 External Sharing and Disclosure 

The following questions are intended to define the content, scope, and authority for information 

sharing external to USDA which includes Federal, state and local government, and the private sector. 

5.1 With which external organization(s) is the information shared, what 

information is shared, and for what purpose? 

• To State/Tribal animal health officials and their contractors and other cooperators 

authorized access by State/Tribal animal health officials, data from their State/Tribe as 

co-owners of the data to: (a) Collaborate with USDA in conducting, managing, and 

evaluating animal health, disease, or pest surveillance or control programs, and 

monitoring for animal health, diseases or pests; (b) aid in containing and responding to 

a foreign or domestic animal disease or pest outbreak, bioterrorism, or other animal 

health emergency; (c) disseminate information and solicit feedback on emergency 

preparedness and response guidelines and the system itself for the purpose of 

educating and involving these officials in program development, program 

requirements, and standards of conduct; and (d) States/Tribes may share information 

on premises, persons, or animals within their State or Tribe in accordance with State 

or Tribal laws and regulations via public websites or other means; 

• To Federal, State/Tribal, or local government agencies involved with public health 

such as the Departments of Health and Human Services and Homeland Security 

(DHS) for the purposes of collaborating with USDA to conduct, manage, or evaluate 

zoonotic disease or pest awareness, surveillance, response or reporting activities, or to 

respond to emergencies impacting humans and domestic animals; 

• When a record on its face, or in conjunction with other records, indicates a 

violation or potential violation of law, whether civil, criminal, or regulatory in 
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nature, and whether arising by general statute or particular program, statute, or by 

regulation, rule, or order issued pursuant thereto, disclosure may be made to the 

appropriate agency, whether Federal, foreign, State, Tribal, local, or other public 

authority responsible for enforcing, investigating, or prosecuting such violation or 

charged with enforcing or implementing the statute, rule, regulation, or order 

issued pursuant thereto, if the information disclosed is relevant to any 

enforcement, regulatory, investigative, or prosecutive responsibility of the 

receiving entity;

• (4) To the Department of Justice when: (a) USDA or any component thereof; or 

(b) any employee of USDA in his or her official capacity, where the Department of 

Justice has agreed to represent the employee; or (c) the United States Government, 

is a party to litigation or has an interest in such litigation, and USDA determines 

that the records are relevant and necessary to the litigation and the use of such 

records by the Department of Justice is therefore deemed by USDA to be for a 

purpose that is compatible with the purpose for which USDA collected the records;

• (5) To a court or adjudicative body in a proceeding when: (a) USDA or any 

component thereof; or (b) any employee of USDA in his or her official capacity; or 

(c) any employee of USDA in his or her individual capacity where USDA has 

agreed to represent the employee; or (d) the United States Government is a party to 

litigation or has an interest in such litigation, and USDA determines that the 

records are both relevant and necessary to the litigation and the use of such records 

is therefore deemed by USDA to be for a purpose that is compatible with the 

purpose for which USDA collected the records;

• (6) To appropriate agencies, entities, and persons when: (a) USDA suspects or has 

confirmed that the security or confidentiality of information in the system of 

records has been compromised; (b) USDA has determined that as a result of the 

suspected or confirmed breach there is a risk of harm to individuals, USDA 

(including its information systems, programs, and operations), the Federal 

Government, or national security; and (c) the disclosure made to such agencies, 

entities, and persons is reasonably necessary to assist in connection with USDA’s 

efforts to respond to the suspected or confirmed compromise and prevent, 

minimize, or remedy such harm;

• (7) To another Federal agency or Federal entity, when information from this 

system of records is reasonably necessary to assist the recipient agency or entity in 

(a) responding to a suspected or confirmed breach or (b) preventing, minimizing, 

or remedying the risk of harm to individuals, the agency (including its information 

systems, programs, and operations), the Federal Government, or national security;

• (8) To contractors their agents, grantees, experts, consultants, and other 

performing or working on a contract, service, grant, cooperative agreement, or 

other assignment for the USDA, when necessary to accomplish an agency function 

related to this system of records. Individuals providing information under this 

routine use are subject to the same Privacy Act requirements and limitation on 

disclosure as are applicable to USDA officers and employees;
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• (9) To a Congressional office in response to an inquiry from that Congressional 

Office made at the written request of the individual about whom the record 

pertains; and

• (10) To the National Archives and Records Administration or other Federal 

Government agencies pursuant to records management inspections being 

conducted under 44 U.S.C. 2904 and 2906. 

5.2 Is the sharing of personally identifiable information outside the 

Department compatible with the original collection? If so, is it 

covered by an appropriate routine use in a SORN? If so, please 

describe. If not, please describe under what legal mechanism the 

program or system is allowed to share the personally identifiable 

information outside of USDA. 

Yes. Where the USDA controls the personally identifiable information in the VSISM; use 

of that information will be governed by an appropriate routine use in Animal Health, 

Disease, and Pest Surveillance and Management System, USDA/APHIS-15. APHIS VS 

works with State authorities on data protection through the use of Non-Disclosure 

Agreements (NDAs), Interconnection Security Agreements (ISAs), Memorandum of 

Understandings (MOUs) and other agreements.

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

When the functionality is implemented to share information it will be shared on a case-bycase basis and there will be situations when it will be shared in bulk using the approved 

reporting and analysis tools. The information will be transmitted electronically in report 

format. If system owner approves system to system external interconnection, this 

connection will be made in a secure manner, conducted per routine uses outlined in the 

related System of Record Notice (SORN), and documented with an Interconnection 

Security Agreement (ISA) with the external sharing partner.

5.4 Privacy Impact Analysis: Given the external sharing, explain the 

privacy risks identified and describe how they were mitigated. 

When, the functionality is implemented to share information it will be in accord with the 

stated purpose and use of the collection. Safeguards, such as, security and privacy 

training for organizational personnel will be required. Governance and technical 

procedures will restrict data access to only those allowed by the user. Finally, all requests 

for the sharing of PII must be reviewed/approved by the VS Executive Leadership, the 

System Owner, the VS Authorizing Officer and the APHIS Information Security Branch.
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Section 6.0 Notice 

The following questions are directed at notice to the individual of the scope of information collected, 

the right to consent to uses of said information, and the right to decline to provide information. 

6.1 Was notice provided to the individual prior to collection of 

information? 

Yes. The APHIS 15 SORN is the official notice.

6.2 Do individuals have the opportunity and/or right to decline to provide 

information? 

Yes. In order to participate in the program individuals must provide information. When 

choosing to participate, individuals must provide certain information in order to receive 

animal health services from APHIS. 

Also, individuals involved in animal disease investigations are required to provide 

information as governed by specific animal health laws and regulations of the state in 

which they reside.

6.3 Do individuals have the right to consent to particular uses of the 

information? If so, how does the individual exercise the right?

No. The use of the information will be noted in the routine uses of the SORN.

6.4 Privacy Impact Analysis: Describe how notice is provided to 

individuals, and how the risks associated with individuals being 

unaware of the collection are mitigated. 

The System of Record Notice is the official notice. No information is collected without an 

individual’s awareness. At the time of data collection, a form is being completed or the 

individual is speaking with a Federal or State employee. Information pertains to health 

status and location of an individual’s animals.

Section 7.0 Access, Redress and Correction 

The following questions are directed at an individual’s ability to ensure the accuracy of the 

information collected about them. 

7.1 What are the procedures that allow individuals to gain access to their 

information? 
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Any individual may obtain information from a record in the system that pertains to 

him or her. Request for hard copies of records should be in writing, and the request 

must contain the requesting individual’s name, address, name of system of records, 

timeframe for the records in question, any other pertinent information to help identify 

the file, and a copy of his/her photo identification containing a current address for 

verification of identification. All inquiries should be addressed to the APHIS Privacy 

Act Officer, Legislative and Public Affairs, APHIS, 4700 River Road Unit 50, 

Riverdale, MD 20737-1232.

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

Any individual may contest information contained within a record in the system that 

pertains to him/her by submitting a written request to the system manager at the 

address above. Include the reason for contesting the record and the proposed 

amendment to the information with supporting documentation to show how the record 

is inaccurate.

7.3 How are individuals notified of the procedures for correcting their 

information? 

Individuals are notified of procedures by the animal health officials at the point of data 

collection.

7.4 If no formal redress is provided, what alternatives are available to the 

individual?

Any individual may contest information contained within a record in the system that 

pertains to him/her by submitting a written request to the system manger to the APHIS 

Privacy Act Officer, Legislative and Public Affairs, APHIS, 4700 River Road Unit 50, 

Riverdale, MD 20737-1232. Include the reason for contesting the record and the proposed 

amendment to the information with supporting documentation to show how the record is 

inaccurate.

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

The primary risk associated with the redress process is latency in making the correction. 

This risk is mitigated by empowering surveillance business representatives to address the 

update without IT intervention. 

Section 8.0 Technical Access and Security 
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The following questions are intended to describe technical safeguards and security measures. 

8.1 What procedures are in place to determine which users may access 

the system and are they documented? 

Access to the USDA APHIS VSISM is based on the need to conduct business with USDA 

and is approved by an authorized APHIS VS official. Criteria, procedures, and controls 

are documented. Access must be requested in writing and approved by the supervisor or 

APHIS authorizing official. 

Once access is authorized, users of USDA APHIS VSISM information are further 

controlled through electronic role-based access. The system is integrated with USDA 

eAuthentication application and requires level 2 authenticated access. Users must have a 

government issued login and password that is controlled and managed either at the 

Veterinary Services district or local VS offices. Password controls, procedures, 

responsibilities and policies follow USDA departmental standards.

8.2 Will Department contractors have access to the system? 

Currently there are no VS IT contractors accessing this system. 

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

All APHIS employees provided access to the USDA APHIS VSISM application are 

required to complete annual Information Technology (IT) Security Awareness Training 

and must sign APHIS Rules of Behavior form prior to receiving access to the information 

system. VS system owners and technical staff are required to complete Protecting PII 

training each year.

8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

Yes. Authority to Operate expires 5/22/2021.

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

In accordance with FIP 199/200 Moderate Baseline Security Controls. Some of the 

technical safeguards for VSISM using Dynamics CRM is a security model that 

includes auditing, role-based views, field-level security, and division of security. This 

means any events, such as create, modify, soft delete, as well as users, and old and 

new values are audited at the field level. Even the audit history on individual record 

and/or audit history summary is also tightly controlled with separate security settings 

to protect the integrity of the log. The security model provides users with access only 

to the appropriate levels of information based on their role(s). Furthermore, views and 
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field-level are role-based as well; preventing users from seeing, accessing, and/or 

making changes to individual fields or records they do not have access to. Finally, 

access control is a combination of eAuthentication (user credential and authentication) 

and authorization (VSISM roles).

8.6 Privacy Impact Analysis: Given the sensitivity and scope of the 

information collected, as well as any information sharing conducted 

on the system, what privacy risks were identified and how do the 

security controls mitigate them? 

Unauthorized disclosure of employee and other personnel information, as identified in 

Section 1.1 above, is the primary privacy risk to information shared both internally and 

externally to the USDA. This risk is mitigated through technical and procedural 

information security controls levied on internal and external holders of USDA APHIS 

VSISM data. USDA APHIS VSISM and MRP Azure Cloud technical security controls are 

delineated in the current USDA APHIS VSISM System Security Plan.

VSISM can only be accessed by personnel who have logged in with their e-Authentication 

PIV or e-authentication username/password credential and have been authorized with 

specific VSISM role(s). If data is retrieved, no record of data queried is kept but 

individual must have user access and rights to access data. User access and changes to 

data are captured in audit logs. Users must be authenticated and have role based access to 

data which is limited on a need-to-know basis to the users business unit and teams (both

state level access and commodity group). 

Section 9.0 Technology 

The following questions are directed at critically analyzing the selection process for any 

technologies utilized by the system, including system hardware and other technology. 

9.1 What type of project is the program or system? 

The USDA APHIS Veterinary Services Integrated Surveillance Modules (VSISM) is a 

major application (MA) that collects, manages, and evaluates animal health data for 

disease management and surveillance programs.

9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 

This application does not employ technology which may raise privacy concerns.

Section 10.0 Third Party Websites/Applications 

The following questions are directed at critically analyzing the privacy impact of using third 

party websites and/or applications. 
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10.1 Has the System Owner (SO) and/or Information Systems Security 

Program Manager (ISSPM) reviewed Office of Management and 

Budget (OMB) memorandums M-10-22 “Guidance for Online Use of 

Web Measurement and Customization Technology” and M-10-23 

“Guidance for Agency Use of Third-Party Websites and 

Applications”?

OMB M-10-23 has been distributed by APHIS VS to the system owner and both have 

been reviewed..

10.2 What is the specific purpose of the agency’s use of 3rd party websites 

and/or applications?

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.3 What personally identifiable information (PII) will become available 

through the agency’s use of 3rd party websites and/or applications.

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.4 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be used?

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.5 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be maintained and secured?

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.6 Is the PII that becomes available through the agency’s use of 3rd party 

websites and/or applications purged periodically? 

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.7 Who will have access to PII that becomes available through the 

agency’s use of 3rd party websites and/or applications?

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.8 With whom will the PII that becomes available through the agency’s 

use of 3rd party websites and/or applications be shared - either 

internally or externally?
Privacy Impact Assessment 

USDA APHIS VSISM

Page 19

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.9 Will the activities involving the PII that becomes available through 

the agency’s use of 3rd party websites and/or applications require 

either the creation or modification of a system of records notice 

(SORN)?

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.10 Does the system use web measurement and customization technology?

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

If so, is the system and procedures reviewed annually to demonstrate compliance to 

OMB M-10-23?

Not applicable. USDA APHIS VSISM does not use third party websites or applications.

10.11 Does the system allow users to either decline to opt-in or decide to 

opt-out of all uses of web measurement and customization 

technology?

Not applicable.

10.12 Privacy Impact Analysis: Given the amount and type of PII that 

becomes available through the agency’s use of 3rd party websites 

and/or applications, discuss the privacy risks identified and how they 

were mitigated. 

Not applicable.
Privacy Impact Assessment 

USDA APHIS VSISM

Page 20

Responsible Officials 

Orlando Baca

System Owner

United States Department of Agriculture

Approval Signature 

________________________________ 

Orlando R. Baca

System Owner

Animal Plant Health Inspection Service

United States Department of Agriculture

________________________________ 

Preston Griffin

MRP Information System Security Program Manager

Animal Plant Health Inspection Service

United States Department of Agriculture

________________________________ 

Tonya G. Woods

Director, Freedom of Information Office

APHIS Privacy Officer 

Animal Plant Health Inspection Service

United States Department of Agriculture